BEPS is an issue that all developing countries are facing. In Thailand, for example, the possible misuse of treaty of benefits affects the effective collection of taxes. Thus, the following OECD action points will be prioritized by the Thai government: digital economy, treaty abuse and transfer pricing. That being said, Thailand will also be joining the implementation of the BEPS action plan, although on its own timeline.

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Base erosion and profit shifting (BEPS) refers to tax avoidance strategies that exploit gaps and mismatches in tax rules to artificially shift profits to low or no-tax locations. Under the inclusive framework, over 100 countries and jurisdictions are collaborating to implement the BEPS measures and tackle BEPS.